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DOCKET NO.: FST-CV20-6047029-S : SUPERIOR COURT
:
DEUTSCHE BANK AG, : JUDICIAL DISTRICT OF
: STAMFORD/NORWALK
Plaintiff, : AT STAMFORD
v. :
: June 29, 2021
CAROLINE VIK, ET AL., :
:
Defendants. :
:
PLAINTIFF’S MOTION FOR AN ORDER OF COMPLIANCE
Pursuant to Practice Book § 13-14, Plaintiff Deutsche Bank AG (“Deutsche Bank”)
respectfully submits this Motion for an Order of Compliance with Plaintiff’s Jurisdictional
Discovery Interrogatories and Requests for the Production of Documents and Things
(collectively, the “Jurisdictional Discovery Requests”) addressed to Defendants Alexander Vik
and Caroline Vik (“Defendants”). Defendants have objected to all of the Jurisdictional
Discovery Requests (see Dkt. Nos. 132.00 and 133.00) and, although Deutsche Bank agreed to
withdraw some requests and narrow others, the parties have been unable to resolve a substantial
number of disputed issues. As set forth in detail in Plaintiff’s memorandum of law in support of
this motion, Plaintiff’s discovery requests are tailored to obtain jurisdictionally-relevant
discovery information that will lead to the resolution of Defendants’ pending motions to dismiss.
Deutsche Bank has made bona fide attempts to resolve Defendants’ objections to these requests,
withdrawing some and narrowing many others. Defendants continue to maintain their objections
to (1) the proposed relevant time period of requested information and documents; and (2)
responding to jurisdictional discovery requests as they pertain to Mr. Vik’s wife or Defendant
Caroline Vik. To date, Defendants have not produced any information or documents in response
to any of Plaintiff’s jurisdictional discovery requests.
WHEREFORE, Deutsche Bank respectfully requests that the Court grant Plaintiff’s
motion and, overrule Defendants’ objections to the Jurisdictional Discovery Requests as outlined
in Appendices A and B.
PLAINTIFF DEUTSCHE BANK AG
By: _/s/ David G. Januszewski______
David G. Januszewski
Juris No. 403654
Sheila C. Ramesh (PHV # 535593)
Cahill Gordon & Reindel LLP
32 Old Slip
New York, New York 10005
Telephone: 212-701-3000
Thomas D. Goldberg
Michael Schoeneberger
Day Pitney LLP
One Stamford Plaza
263 Tresser Boulevard
Stamford, CT 06901
Telephone: 203-977-7300
Attorneys for Plaintiff Deutsche Bank AG
-2-
DOCKET NO. FST-CV20-6047029-S : SUPERIOR COURT
:
DEUTSCHE BANK AG, : JUDICIAL DISTRICT OF
: STAMFORD/NORWALK
Plaintiff, : AT STAMFORD
v. :
: June 29, 2021
CAROLINE VIK, ET AL., :
:
Defendants. :
:
CERTIFICATE OF SERVICE
I hereby certify that a copy of the attached was sent via electronic mail to the
following counsel of record for Defendants:
Monte E. Frank
Adam Mocciolo
Johanna S. Katz
Julie Pinette
Pullman & Comley, LLC
850 Main Street P.O. Box 7006
Bridgeport, Connecticut 06601
mfrank@pullcom.com
amocciolo@pullcom.com
jkatz@pullcom.com
jpinette@pullcom.com
_/s/ Michael Schoeneberger
Michael Schoeneberger
-3-
APPENDIX A: TABLE OF JURISDICTIONAL DISCOVERY NEGOTIATIONS
FOR ALEXANDER VIK
Req. DB Original Original Objections/Responses Deutsche Bank Revised Vik Objections/Responses
No. Jurisdictional Discovery (February 16, 2021) Jurisdictional Discovery (March 8, 2021 Ltr from
(Dec. 17, 2020) (February 25, 2021) Monte Frank to Tom
Goldberg)
Interrogatories for Alexander Vik
1 Identify all names, This interrogatory is unduly Identify all names, You did not revise this
addresses, and account burdensome, not proportional to the addresses, and account interrogatory other than to
numbers of all bank, needs of jurisdictional discovery, numbers of all bank, delete “children”, and our
brokerage, or other asset overbroad, vague, and not reasonably brokerage, or other asset objection stands.
accounts in Connecticut calculated to lead to the discovery of accounts in Connecticut
maintained on Your admissible evidence. See Practice maintained on Your
behalf, on behalf of your Book § 13-2. In addition, the behalf, on behalf of your
wife or children, or on interrogatory seeks information about wife, or on behalf of
behalf of entities that you individuals who are not parties to this entities that you own or
own or operate or have an case and accounts, if they even exist, operate or have an interest
interest in. in which Mr. Vik does not have an in.
interest, nor does he have access,
control or personal knowledge.
Finally, what Mr. Vik may have
owned outside of a small window
prior to the apparent date of service is
not material to the jurisdictional issues
raised in the motions to dismiss.
2 Identify all safe deposit This interrogatory is unduly Identify all safe deposit You did not revise this
boxes in Connecticut burdensome, not proportional to the boxes in Connecticut interrogatory other than to
maintained on Your needs of jurisdictional discovery, maintained on Your delete “children”, and our
behalf, on behalf of your overbroad, vague, and not reasonably behalf, on behalf of your objection stands. Without
wife or children, or on calculated to lead to the discovery of wife, or on behalf of waiving the objection and
behalf of entities You admissible evidence. See Practice entities You own, operate, subject to it, we will answer
Book § 13-2. In addition, the or have an interest in. for Mr. Vik only.
own, operate, or have an interrogatory seeks information about
interest in. individuals who are not parties to this
case and safe deposit boxes, if they
even exist, in which Mr. Vik does not
have interest, nor does he have access,
control or personal knowledge.
Finally, what Mr. Vik may have
owned outside of a small window
prior to the apparent date of service is
not material to the jurisdictional issues
raised in the motions to dismiss.
3 Identify all names, This interrogatory is unduly Identify all names, Your revision did not fully
addresses, and ownership burdensome, not proportional to the addresses, and ownership address our objection.
stakes or interests of all needs of jurisdictional discovery, stakes or interests of all Without waiving the
accounts, goods, assets, overbroad, vague, and not reasonably trusts, estates, real objection and subject to it,
trusts, estates, properties calculated to lead to the discovery of properties, and other we will answer for Mr. Vik
(real or otherwise), admissible evidence. See Practice privately-held businesses only.
companies, and other Book § 13-2. By way of example, the or entities in Connecticut
businesses or entities in interrogatory seeks the identification in which You have any
Connecticut in which You of publicly traded companies that beneficial interest or
have any beneficial happen to be located in Connecticut in complete or partial
interest or complete or which Mr. Vik may own shares, no ownership and/or control.
partial ownership and/or matter how insignificant his holding,
control. or a municipal bond fund that may
contain a Connecticut municipality.
Identifying these types of investments,
while potentially responsive, are not
material to the jurisdictional issues
raised in the motions to dismiss.
Finally, what Mr. Vik may have
owned outside of a small window
prior to the date of service is not
2
material to the jurisdictional issues
raised in the motions to dismiss.
4 For each year during the This interrogatory is unduly For each year during the You did not revise your
relevant period, state the burdensome, not proportional to the relevant period, state the interrogatory, and our
following: needs of jurisdictional discovery, following: objection stands. In
a. the number of days overbroad, vague, and not reasonably a. the number of days addition, the interrogatory
on which You were calculated to lead to the discovery of on which You were cannot be answered based
present at 10 Ashton admissible evidence. See Practice present at 10 Ashton on the information
Drive; Book § 13-2. In addition, the Drive; reasonably available to Mr.
b. the number of days interrogatory seeks information about b. the number of days Vik.
on which your wife was Mr. Vik’s wife even though she is not on which your wife was
present at 10 Ashton a party to this case. Finally, where Mr. present at 10 Ashton
Drive. Vik may have been outside of a Drive.
relevant period prior to the apparent
date of service is not material to the
jurisdictional issues raised in the
motions to dismiss.
5 Identify the categories of This interrogatory is unduly Identify the categories of You did not revise this
personal possessions You burdensome, not proportional to the personal possessions You interrogatory, and our
maintain at 10 Ashton needs of jurisdictional discovery, maintain at 10 Ashton objection stands. Without
Dive, including but not overbroad, vague, and not reasonably Drive, including but not waiving the objection and
limited to clothing, calculated to lead to the discovery of limited to clothing, subject to it, Mr. Vik’s
toiletries, prescription admissible evidence. See Practice toiletries, prescription personal possessions for the
medication, and other Book § 13-2. Finally, what Mr. Vik medication, and other categories enumerated are
affects. may have “maintained’ at 10 Ashton affects. de minimis, and we will
Drive outside of a small window prior answer accordingly.
to the apparent date of service is not
material to the jurisdictional issues
raised in the motions to dismiss.
6 Identify the mail This interrogatory is unduly Identify (a) all periodicals Our objection stands. In
addressed to You at 10 burdensome, not proportional to the for which a subscription addition, it is not possible
Ashton Drive, including needs of jurisdictional discovery, fee is paid and which are for Mr. Vik to answer
magazines, newspapers, overbroad, vague, and not reasonably regularly mailed to 10 without physically being at
3
and other periodicals, or calculated to lead to the discovery of Ashton Drive, including 10 Ashton Drive. Since he
financial statements, admissible evidence. See Practice but not limited to does not live there, has not
including bills and Book § 13-2. In addition, the magazines, newspapers, been there in some time,
invoices, which are interrogatory seeks information about and catalogs, addressed to and has no current plans to
addressed to You or Mr. Vik’s wife even though she is not You, individually or visit, we cannot answer this
jointly addressed to You a party to this case. Moreover, jointly, and (b) all interrogatory at this time.
and your wife. whether a third party addressed a financial statements,
magazine or junk mail, for example, to including bills and
Mr. Vik at 10 Ashton Drive based on invoices, which are
what might have been his address a regularly mailed to 10
time ago, as seems to be the bank’s Ashton Drive and
focus, has no bearing on personal addressed to You,
jurisdiction over Mr. Vik as of the individually or jointly
apparent date of service. Finally, what
mail may have been addressed to Mr.
Vik outside of a relevant period prior
to the apparent date of service is not
material to the jurisdictional issues
raised in the motions to dismiss.
7 Identify whether You, This interrogatory is unduly Identify whether You, Without waiving the
your wife, or any other burdensome, not proportional to the your wife, or any other objection and subject to it,
person who lives or works needs of jurisdictional discovery, person who lives or works Mr. Vik will answer.
at 10 Ashton Drive has overbroad, vague, and not reasonably at 10 Ashton Drive has
accepted service of calculated to lead to the discovery of accepted service of
process there and identify admissible evidence. See Practice process there and identify
the dates and matter(s) for Book § 13-2. In addition, the the dates and matter(s) for
which process was interrogatory seeks information about which process was
received or accepted. Mr. Vik’s wife or other persons who received or accepted.
live or work at 10 Ashton Drive even
though they are not parties to this
case. For example, if someone who
works at 10 Ashton Drive, not
employed by Mr. Vik, had been
4
served as a defendant in a personal
injury case while at 10 Ashton Drive,
assuming Mr. Vik knew that
information, it would be responsive to
the interrogatory, but immaterial to the
jurisdictional issues raised in the
motions to dismiss. Finally, the time
period requested is overly broad and
unduly burdensome and not material
to the jurisdictional issues raised in the
motions to dismiss.
8 Identify the following with This interrogatory is unduly Identify the following Without waiving the
respect to the State of burdensome, not proportional to the with respect to the State of objection and subject to it,
Connecticut’s Department needs of jurisdictional discovery, Connecticut’s Department Mr. Vik will answer.
of Motor Vehicles: overbroad, vague, and not reasonably of Motor Vehicles:
a. whether You have calculated to lead to the discovery of a. whether You have
ever been licensed to drive admissible evidence. See Practice ever been licensed to drive
in the State of Book § 13-2. The time period in the State of
Connecticut; requested is overly broad and unduly Connecticut;
b. whether You have burdensome and not material to the b. whether You have
ever applied for a driver’s jurisdictional issues raised in the applied for a driver’s
license in the State of motions to dismiss. license or renewed an
Connecticut; existing driver’s license in
c. when You first the State of Connecticut
received your driver’s since January 2019;
license in the State of c. when You first
Connecticut; received your driver’s
d. when You last license in the State of
renewed your driver’s Connecticut;
license in the State of d. when You last
Connecticut; renewed your driver’s
e. whether You have license in the State of
ever registered a motor Connecticut;
5
vehicle in your name in e. whether You have
the State of Connecticut; ever registered a motor
f. whether You have vehicle in your name in
ever appeared on a motor the State of Connecticut;
vehicle registration in the f. whether You have
State of Connecticut; ever appeared on a motor
g. whether You have vehicle registration in the
ever been insured to drive State of Connecticut;
a motor vehicle in the g. whether You have
State of Connecticut. ever been insured to drive
a motor vehicle in the
State of Connecticut.
9 Identify any cars or other This interrogatory is unduly Identify any cars or other Without waiving the
motorized vehicles burdensome, not proportional to the motorized vehicles objection and subject to it,
(including watercrafts or needs of jurisdictional discovery, (including watercrafts or Mr. Vik will answer for
aircrafts) You, your wife, overbroad, vague, and not reasonably aircrafts) You or your himself only.
or your children have calculated to lead to the discovery of wife have owned, leased,
owned, leased, admissible evidence. See Practice maintained, or used in
maintained, or used in Book § 13-2. In addition, the Connecticut from January
Connecticut from January interrogatory seeks information about 2017 through the present.
2000 through the present. individuals who are not parties to this
case and vehicles, if they even exist, in
which Mr. Vik does not have an
interest or control, and may not have
knowledge. For example, if one of his
adult daughters rented a car in
Connecticut, that act is not material to
the jurisdictional issues raised in the
motions to dismiss (or any other
aspect of this case). Finally, what
vehicles Mr. Vik or anyone else may
have owned, leased, maintained, or
used in Connecticut outside of a small
6
window prior to the apparent date of
service is not material to the
jurisdictional issues raised in the
motions to dismiss.
10 Identify whether You, This interrogatory is unduly Identify whether You or Without waiving the
your wife, or children burdensome, not proportional to the your wife have filed objection and subject to it,
have filed federal or needs of jurisdictional discovery, federal or Connecticut Mr. Vik will answer for
Connecticut state income overbroad, vague, and not reasonably state income tax returns or himself only.
tax returns or paid any calculated to lead to the discovery of paid any local taxes or
local taxes or fees admissible evidence. See Practice fees (including property
(including property taxes) Book § 13-2. In addition, the taxes) to the Town of
to the Town of Greenwich, interrogatory seeks information about Greenwich, Connecticut
Connecticut from January individuals who are not parties to this from January 2017
2000 through the present. case. Finally, the time period through the present.
requested is overly broad and unduly
burdensome and not material to the
jurisdictional issues raised in the
motions to dismiss.
11 Identify whether You, This interrogatory is unduly Identify whether You or Without waiving the
your wife, or children burdensome, not proportional to the your wife have held a objection and subject to it,
have held a Park Pass needs of jurisdictional discovery, Park Pass issued by the Mr. Vik will answer for
issued by the Town of overbroad, vague, and not reasonably Town of Greenwich, himself only.
Greenwich, Connecticut at calculated to lead to the discovery of Connecticut at any time
any time between January admissible evidence. See Practice between January 2017 and
2000 and the present. Book § 13-2. In addition, the the present.
interrogatory seeks information about
individuals who are not parties to this
case. For example, if one of his adult
daughters purchased a Park Pass, that
act is not material to the jurisdictional
issues raised in the motions to dismiss
(or any other aspect of this case).
Finally, whether Mr. Vik bought a
7
Park Pass outside of a small window
prior to the apparent date of service is
not material to the jurisdictional issues
raised in the motions to dismiss.
12 Identify any athletic clubs, This interrogatory is unduly Identify any athletic clubs Without waiving the
country clubs, or sports burdensome, not proportional to the or country clubs, to which objection and subject to it,
teams to which You or needs of jurisdictional discovery, You or your wife have Mr. Vik will answer for
your wife have belonged overbroad, vague, and not reasonably belonged in Connecticut himself only.
in Connecticut between calculated to lead to the discovery of between January 2017 and
January 2000 and the admissible evidence. See Practice the present.
present. Book § 13-2. In addition, the
interrogatory seeks information about
individuals who are not parties to this
case. For example, if Mr. Vik’s wife
joined a gym, that act is not material
to the jurisdictional issues raised in the
motions to dismiss (or any other
aspect of this case). Finally, whether
Mr. Vik joined a club outside of a
small window prior to the apparent
date of service is not material to the
jurisdictional issues raised in the
motions to dismiss.
13 Identify any fitness This interrogatory is unduly Identify any fitness Without waiving the
studios, classes, or burdensome, not proportional to the studios, classes, or objection and subject to it,
associations which You needs of jurisdictional discovery, associations which You Mr. Vik will answer.
have attended or in which overbroad, vague, and not reasonably have attended or in which
you have participated in calculated to lead to the discovery of you have participated in
the State of Connecticut admissible evidence. See Practice the State of Connecticut
between January 2000 and Book § 13-2. Whether Mr. Vik between January 2017 and
the present. attended a fitness class prior to the the present.
apparent date of service is not material
8
to the jurisdictional issues raised in the
motions to dismiss.
14 Identify all persons who This interrogatory is unduly Identify all persons who Without waiving the
live at 10 Ashton Drive burdensome, not proportional to the live at 10 Ashton Drive objection and subject to it,
from January 1, 2017 to needs of jurisdictional discovery, from January 1, 2017 to Mr. Vik will answer.
present. overbroad, vague, and not reasonably present.
calculated to lead to the discovery of
admissible evidence. See Practice
Book § 13-2. In addition, the
interrogatory seeks information about
individuals who are not parties to this
case. Finally, Mr. Vik objects to the
time period requested as it is not
material to the jurisdictional issues
raised in the motions to dismiss.
15 Identify all persons who This interrogatory is unduly Identify all persons who Without waiving the
work at 10 Ashton Drive, burdensome, not proportional to the have been contracted or objection and subject to it,
including maids, cleaning needs of jurisdictional discovery, employed by You or your Mr. Vik will answer for
staff, gardening staff, and overbroad, vague, and not reasonably wife, or any entity owned himself only.
employees, agents, or calculated to lead to the discovery of or controlled by You or
third-party contractors, or admissible evidence. See Practice your wife, to work at 10
any other entities or Book § 13-2. In addition, the Ashton Drive, including
businesses which operate interrogatory seeks information about maids, cleaning staff,
or have operated from 10 individuals and entities who are not gardening staff, and third-
Ashton Drive. parties to this case. For example, if party contractors, or any
Mrs. Vik, the owner of the house, other entities or
hired someone to paint a bathroom, businesses which operate
the identity of that person is not or have operated from 10
material to the jurisdictional issues Ashton Drive from
raised in the motions to dismiss. January 1, 2017 to
Finally, Mr. Vik objects to the time present.
period requested as it is not material to
9
the jurisdictional issues raised in the
motions to dismiss.
16 Identify any religious This interrogatory is unduly Identify any religious Without waiving the
organization in the State burdensome, not proportional to the organization in the State objection and subject to it,
of Connecticut, including needs of jurisdictional discovery, of Connecticut, including Mr. Vik will answer.
churches, to which You overbroad, vague, and not reasonably churches, to which You
are/were a member, calculated to lead to the discovery of are/were a member or
attended, or made a admissible evidence. See Practice attended services between
charitable contribution Book § 13-2. For example, if Mr. Vik January 1, 2017 and the
between January 1, 2017 made a contribution to a church present, including:
and the present, including: operating a soup kitchen in c. An approximation of
a. The frequency with Connecticut, the identity of that the frequency with which
which You attend(ed) organization is not material to the You attend(ed) services;
services; and jurisdictional issues raised in the and
b. The time period motions to dismiss. Finally, Mr. Vik d. An approximate
during which You were or objects to the time period requested as time period during which
have been a member of the it is not material to the jurisdictional You were or have been a
organization(s). issues raised in the motions to dismiss. member of the
organization(s).
17 Identify all charities, This interrogatory is unduly Identify all charities, Without waiving the
groups, clubs, or other burdensome, not proportional to the groups, clubs, or other objection and subject to it,
organizations which You, needs of jurisdictional discovery, non-profit organizations Mr. Vik will answer for
your wife, or children overbroad, vague, and not reasonably which You or your wife himself only.
have been involved in or calculated to lead to the discovery of have been involved in or
have donated money to in admissible evidence. See Practice have donated money to in
the State of Connecticut Book § 13-2. In addition, the the State of Connecticut
between January 2000 and i
Preview
DOCKET NO.: FST-CV20-6047029-S : SUPERIOR COURT : DEUTSCHE BANK AG, : JUDICIAL DISTRICT OF : STAMFORD/NORWALK Plaintiff, : AT STAMFORD v. : : June 29, 2021 CAROLINE VIK, ET AL., : : Defendants. : : PLAINTIFF’S MOTION FOR AN ORDER OF COMPLIANCE Pursuant to Practice Book § 13-14, Plaintiff Deutsche Bank AG (“Deutsche Bank”) respectfully submits this Motion for an Order of Compliance with Plaintiff’s Jurisdictional Discovery Interrogatories and Requests for the Production of Documents and Things (collectively, the “Jurisdictional Discovery Requests”) addressed to Defendants Alexander Vik and Caroline Vik (“Defendants”). Defendants have objected to all of the Jurisdictional Discovery Requests (see Dkt. Nos. 132.00 and 133.00) and, although Deutsche Bank agreed to withdraw some requests and narrow others, the parties have been unable to resolve a substantial number of disputed issues. As set forth in detail in Plaintiff’s memorandum of law in support of this motion, Plaintiff’s discovery requests are tailored to obtain jurisdictionally-relevant discovery information that will lead to the resolution of Defendants’ pending motions to dismiss. Deutsche Bank has made bona fide attempts to resolve Defendants’ objections to these requests, withdrawing some and narrowing many others. Defendants continue to maintain their objections to (1) the proposed relevant time period of requested information and documents; and (2) responding to jurisdictional discovery requests as they pertain to Mr. Vik’s wife or Defendant Caroline Vik. To date, Defendants have not produced any information or documents in response to any of Plaintiff’s jurisdictional discovery requests. WHEREFORE, Deutsche Bank respectfully requests that the Court grant Plaintiff’s motion and, overrule Defendants’ objections to the Jurisdictional Discovery Requests as outlined in Appendices A and B. PLAINTIFF DEUTSCHE BANK AG By: _/s/ David G. Januszewski______ David G. Januszewski Juris No. 403654 Sheila C. Ramesh (PHV # 535593) Cahill Gordon & Reindel LLP 32 Old Slip New York, New York 10005 Telephone: 212-701-3000 Thomas D. Goldberg Michael Schoeneberger Day Pitney LLP One Stamford Plaza 263 Tresser Boulevard Stamford, CT 06901 Telephone: 203-977-7300 Attorneys for Plaintiff Deutsche Bank AG -2- DOCKET NO. FST-CV20-6047029-S : SUPERIOR COURT : DEUTSCHE BANK AG, : JUDICIAL DISTRICT OF : STAMFORD/NORWALK Plaintiff, : AT STAMFORD v. : : June 29, 2021 CAROLINE VIK, ET AL., : : Defendants. : : CERTIFICATE OF SERVICE I hereby certify that a copy of the attached was sent via electronic mail to the following counsel of record for Defendants: Monte E. Frank Adam Mocciolo Johanna S. Katz Julie Pinette Pullman & Comley, LLC 850 Main Street P.O. Box 7006 Bridgeport, Connecticut 06601 mfrank@pullcom.com amocciolo@pullcom.com jkatz@pullcom.com jpinette@pullcom.com _/s/ Michael Schoeneberger Michael Schoeneberger -3- APPENDIX A: TABLE OF JURISDICTIONAL DISCOVERY NEGOTIATIONS FOR ALEXANDER VIK Req. DB Original Original Objections/Responses Deutsche Bank Revised Vik Objections/Responses No. Jurisdictional Discovery (February 16, 2021) Jurisdictional Discovery (March 8, 2021 Ltr from (Dec. 17, 2020) (February 25, 2021) Monte Frank to Tom Goldberg) Interrogatories for Alexander Vik 1 Identify all names, This interrogatory is unduly Identify all names, You did not revise this addresses, and account burdensome, not proportional to the addresses, and account interrogatory other than to numbers of all bank, needs of jurisdictional discovery, numbers of all bank, delete “children”, and our brokerage, or other asset overbroad, vague, and not reasonably brokerage, or other asset objection stands. accounts in Connecticut calculated to lead to the discovery of accounts in Connecticut maintained on Your admissible evidence. See Practice maintained on Your behalf, on behalf of your Book § 13-2. In addition, the behalf, on behalf of your wife or children, or on interrogatory seeks information about wife, or on behalf of behalf of entities that you individuals who are not parties to this entities that you own or own or operate or have an case and accounts, if they even exist, operate or have an interest interest in. in which Mr. Vik does not have an in. interest, nor does he have access, control or personal knowledge. Finally, what Mr. Vik may have owned outside of a small window prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 2 Identify all safe deposit This interrogatory is unduly Identify all safe deposit You did not revise this boxes in Connecticut burdensome, not proportional to the boxes in Connecticut interrogatory other than to maintained on Your needs of jurisdictional discovery, maintained on Your delete “children”, and our behalf, on behalf of your overbroad, vague, and not reasonably behalf, on behalf of your objection stands. Without wife or children, or on calculated to lead to the discovery of wife, or on behalf of waiving the objection and behalf of entities You admissible evidence. See Practice entities You own, operate, subject to it, we will answer Book § 13-2. In addition, the or have an interest in. for Mr. Vik only. own, operate, or have an interrogatory seeks information about interest in. individuals who are not parties to this case and safe deposit boxes, if they even exist, in which Mr. Vik does not have interest, nor does he have access, control or personal knowledge. Finally, what Mr. Vik may have owned outside of a small window prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 3 Identify all names, This interrogatory is unduly Identify all names, Your revision did not fully addresses, and ownership burdensome, not proportional to the addresses, and ownership address our objection. stakes or interests of all needs of jurisdictional discovery, stakes or interests of all Without waiving the accounts, goods, assets, overbroad, vague, and not reasonably trusts, estates, real objection and subject to it, trusts, estates, properties calculated to lead to the discovery of properties, and other we will answer for Mr. Vik (real or otherwise), admissible evidence. See Practice privately-held businesses only. companies, and other Book § 13-2. By way of example, the or entities in Connecticut businesses or entities in interrogatory seeks the identification in which You have any Connecticut in which You of publicly traded companies that beneficial interest or have any beneficial happen to be located in Connecticut in complete or partial interest or complete or which Mr. Vik may own shares, no ownership and/or control. partial ownership and/or matter how insignificant his holding, control. or a municipal bond fund that may contain a Connecticut municipality. Identifying these types of investments, while potentially responsive, are not material to the jurisdictional issues raised in the motions to dismiss. Finally, what Mr. Vik may have owned outside of a small window prior to the date of service is not 2 material to the jurisdictional issues raised in the motions to dismiss. 4 For each year during the This interrogatory is unduly For each year during the You did not revise your relevant period, state the burdensome, not proportional to the relevant period, state the interrogatory, and our following: needs of jurisdictional discovery, following: objection stands. In a. the number of days overbroad, vague, and not reasonably a. the number of days addition, the interrogatory on which You were calculated to lead to the discovery of on which You were cannot be answered based present at 10 Ashton admissible evidence. See Practice present at 10 Ashton on the information Drive; Book § 13-2. In addition, the Drive; reasonably available to Mr. b. the number of days interrogatory seeks information about b. the number of days Vik. on which your wife was Mr. Vik’s wife even though she is not on which your wife was present at 10 Ashton a party to this case. Finally, where Mr. present at 10 Ashton Drive. Vik may have been outside of a Drive. relevant period prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 5 Identify the categories of This interrogatory is unduly Identify the categories of You did not revise this personal possessions You burdensome, not proportional to the personal possessions You interrogatory, and our maintain at 10 Ashton needs of jurisdictional discovery, maintain at 10 Ashton objection stands. Without Dive, including but not overbroad, vague, and not reasonably Drive, including but not waiving the objection and limited to clothing, calculated to lead to the discovery of limited to clothing, subject to it, Mr. Vik’s toiletries, prescription admissible evidence. See Practice toiletries, prescription personal possessions for the medication, and other Book § 13-2. Finally, what Mr. Vik medication, and other categories enumerated are affects. may have “maintained’ at 10 Ashton affects. de minimis, and we will Drive outside of a small window prior answer accordingly. to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 6 Identify the mail This interrogatory is unduly Identify (a) all periodicals Our objection stands. In addressed to You at 10 burdensome, not proportional to the for which a subscription addition, it is not possible Ashton Drive, including needs of jurisdictional discovery, fee is paid and which are for Mr. Vik to answer magazines, newspapers, overbroad, vague, and not reasonably regularly mailed to 10 without physically being at 3 and other periodicals, or calculated to lead to the discovery of Ashton Drive, including 10 Ashton Drive. Since he financial statements, admissible evidence. See Practice but not limited to does not live there, has not including bills and Book § 13-2. In addition, the magazines, newspapers, been there in some time, invoices, which are interrogatory seeks information about and catalogs, addressed to and has no current plans to addressed to You or Mr. Vik’s wife even though she is not You, individually or visit, we cannot answer this jointly addressed to You a party to this case. Moreover, jointly, and (b) all interrogatory at this time. and your wife. whether a third party addressed a financial statements, magazine or junk mail, for example, to including bills and Mr. Vik at 10 Ashton Drive based on invoices, which are what might have been his address a regularly mailed to 10 time ago, as seems to be the bank’s Ashton Drive and focus, has no bearing on personal addressed to You, jurisdiction over Mr. Vik as of the individually or jointly apparent date of service. Finally, what mail may have been addressed to Mr. Vik outside of a relevant period prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 7 Identify whether You, This interrogatory is unduly Identify whether You, Without waiving the your wife, or any other burdensome, not proportional to the your wife, or any other objection and subject to it, person who lives or works needs of jurisdictional discovery, person who lives or works Mr. Vik will answer. at 10 Ashton Drive has overbroad, vague, and not reasonably at 10 Ashton Drive has accepted service of calculated to lead to the discovery of accepted service of process there and identify admissible evidence. See Practice process there and identify the dates and matter(s) for Book § 13-2. In addition, the the dates and matter(s) for which process was interrogatory seeks information about which process was received or accepted. Mr. Vik’s wife or other persons who received or accepted. live or work at 10 Ashton Drive even though they are not parties to this case. For example, if someone who works at 10 Ashton Drive, not employed by Mr. Vik, had been 4 served as a defendant in a personal injury case while at 10 Ashton Drive, assuming Mr. Vik knew that information, it would be responsive to the interrogatory, but immaterial to the jurisdictional issues raised in the motions to dismiss. Finally, the time period requested is overly broad and unduly burdensome and not material to the jurisdictional issues raised in the motions to dismiss. 8 Identify the following with This interrogatory is unduly Identify the following Without waiving the respect to the State of burdensome, not proportional to the with respect to the State of objection and subject to it, Connecticut’s Department needs of jurisdictional discovery, Connecticut’s Department Mr. Vik will answer. of Motor Vehicles: overbroad, vague, and not reasonably of Motor Vehicles: a. whether You have calculated to lead to the discovery of a. whether You have ever been licensed to drive admissible evidence. See Practice ever been licensed to drive in the State of Book § 13-2. The time period in the State of Connecticut; requested is overly broad and unduly Connecticut; b. whether You have burdensome and not material to the b. whether You have ever applied for a driver’s jurisdictional issues raised in the applied for a driver’s license in the State of motions to dismiss. license or renewed an Connecticut; existing driver’s license in c. when You first the State of Connecticut received your driver’s since January 2019; license in the State of c. when You first Connecticut; received your driver’s d. when You last license in the State of renewed your driver’s Connecticut; license in the State of d. when You last Connecticut; renewed your driver’s e. whether You have license in the State of ever registered a motor Connecticut; 5 vehicle in your name in e. whether You have the State of Connecticut; ever registered a motor f. whether You have vehicle in your name in ever appeared on a motor the State of Connecticut; vehicle registration in the f. whether You have State of Connecticut; ever appeared on a motor g. whether You have vehicle registration in the ever been insured to drive State of Connecticut; a motor vehicle in the g. whether You have State of Connecticut. ever been insured to drive a motor vehicle in the State of Connecticut. 9 Identify any cars or other This interrogatory is unduly Identify any cars or other Without waiving the motorized vehicles burdensome, not proportional to the motorized vehicles objection and subject to it, (including watercrafts or needs of jurisdictional discovery, (including watercrafts or Mr. Vik will answer for aircrafts) You, your wife, overbroad, vague, and not reasonably aircrafts) You or your himself only. or your children have calculated to lead to the discovery of wife have owned, leased, owned, leased, admissible evidence. See Practice maintained, or used in maintained, or used in Book § 13-2. In addition, the Connecticut from January Connecticut from January interrogatory seeks information about 2017 through the present. 2000 through the present. individuals who are not parties to this case and vehicles, if they even exist, in which Mr. Vik does not have an interest or control, and may not have knowledge. For example, if one of his adult daughters rented a car in Connecticut, that act is not material to the jurisdictional issues raised in the motions to dismiss (or any other aspect of this case). Finally, what vehicles Mr. Vik or anyone else may have owned, leased, maintained, or used in Connecticut outside of a small 6 window prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 10 Identify whether You, This interrogatory is unduly Identify whether You or Without waiving the your wife, or children burdensome, not proportional to the your wife have filed objection and subject to it, have filed federal or needs of jurisdictional discovery, federal or Connecticut Mr. Vik will answer for Connecticut state income overbroad, vague, and not reasonably state income tax returns or himself only. tax returns or paid any calculated to lead to the discovery of paid any local taxes or local taxes or fees admissible evidence. See Practice fees (including property (including property taxes) Book § 13-2. In addition, the taxes) to the Town of to the Town of Greenwich, interrogatory seeks information about Greenwich, Connecticut Connecticut from January individuals who are not parties to this from January 2017 2000 through the present. case. Finally, the time period through the present. requested is overly broad and unduly burdensome and not material to the jurisdictional issues raised in the motions to dismiss. 11 Identify whether You, This interrogatory is unduly Identify whether You or Without waiving the your wife, or children burdensome, not proportional to the your wife have held a objection and subject to it, have held a Park Pass needs of jurisdictional discovery, Park Pass issued by the Mr. Vik will answer for issued by the Town of overbroad, vague, and not reasonably Town of Greenwich, himself only. Greenwich, Connecticut at calculated to lead to the discovery of Connecticut at any time any time between January admissible evidence. See Practice between January 2017 and 2000 and the present. Book § 13-2. In addition, the the present. interrogatory seeks information about individuals who are not parties to this case. For example, if one of his adult daughters purchased a Park Pass, that act is not material to the jurisdictional issues raised in the motions to dismiss (or any other aspect of this case). Finally, whether Mr. Vik bought a 7 Park Pass outside of a small window prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 12 Identify any athletic clubs, This interrogatory is unduly Identify any athletic clubs Without waiving the country clubs, or sports burdensome, not proportional to the or country clubs, to which objection and subject to it, teams to which You or needs of jurisdictional discovery, You or your wife have Mr. Vik will answer for your wife have belonged overbroad, vague, and not reasonably belonged in Connecticut himself only. in Connecticut between calculated to lead to the discovery of between January 2017 and January 2000 and the admissible evidence. See Practice the present. present. Book § 13-2. In addition, the interrogatory seeks information about individuals who are not parties to this case. For example, if Mr. Vik’s wife joined a gym, that act is not material to the jurisdictional issues raised in the motions to dismiss (or any other aspect of this case). Finally, whether Mr. Vik joined a club outside of a small window prior to the apparent date of service is not material to the jurisdictional issues raised in the motions to dismiss. 13 Identify any fitness This interrogatory is unduly Identify any fitness Without waiving the studios, classes, or burdensome, not proportional to the studios, classes, or objection and subject to it, associations which You needs of jurisdictional discovery, associations which You Mr. Vik will answer. have attended or in which overbroad, vague, and not reasonably have attended or in which you have participated in calculated to lead to the discovery of you have participated in the State of Connecticut admissible evidence. See Practice the State of Connecticut between January 2000 and Book § 13-2. Whether Mr. Vik between January 2017 and the present. attended a fitness class prior to the the present. apparent date of service is not material 8 to the jurisdictional issues raised in the motions to dismiss. 14 Identify all persons who This interrogatory is unduly Identify all persons who Without waiving the live at 10 Ashton Drive burdensome, not proportional to the live at 10 Ashton Drive objection and subject to it, from January 1, 2017 to needs of jurisdictional discovery, from January 1, 2017 to Mr. Vik will answer. present. overbroad, vague, and not reasonably present. calculated to lead to the discovery of admissible evidence. See Practice Book § 13-2. In addition, the interrogatory seeks information about individuals who are not parties to this case. Finally, Mr. Vik objects to the time period requested as it is not material to the jurisdictional issues raised in the motions to dismiss. 15 Identify all persons who This interrogatory is unduly Identify all persons who Without waiving the work at 10 Ashton Drive, burdensome, not proportional to the have been contracted or objection and subject to it, including maids, cleaning needs of jurisdictional discovery, employed by You or your Mr. Vik will answer for staff, gardening staff, and overbroad, vague, and not reasonably wife, or any entity owned himself only. employees, agents, or calculated to lead to the discovery of or controlled by You or third-party contractors, or admissible evidence. See Practice your wife, to work at 10 any other entities or Book § 13-2. In addition, the Ashton Drive, including businesses which operate interrogatory seeks information about maids, cleaning staff, or have operated from 10 individuals and entities who are not gardening staff, and third- Ashton Drive. parties to this case. For example, if party contractors, or any Mrs. Vik, the owner of the house, other entities or hired someone to paint a bathroom, businesses which operate the identity of that person is not or have operated from 10 material to the jurisdictional issues Ashton Drive from raised in the motions to dismiss. January 1, 2017 to Finally, Mr. Vik objects to the time present. period requested as it is not material to 9 the jurisdictional issues raised in the motions to dismiss. 16 Identify any religious This interrogatory is unduly Identify any religious Without waiving the organization in the State burdensome, not proportional to the organization in the State objection and subject to it, of Connecticut, including needs of jurisdictional discovery, of Connecticut, including Mr. Vik will answer. churches, to which You overbroad, vague, and not reasonably churches, to which You are/were a member, calculated to lead to the discovery of are/were a member or attended, or made a admissible evidence. See Practice attended services between charitable contribution Book § 13-2. For example, if Mr. Vik January 1, 2017 and the between January 1, 2017 made a contribution to a church present, including: and the present, including: operating a soup kitchen in c. An approximation of a. The frequency with Connecticut, the identity of that the frequency with which which You attend(ed) organization is not material to the You attend(ed) services; services; and jurisdictional issues raised in the and b. The time period motions to dismiss. Finally, Mr. Vik d. An approximate during which You were or objects to the time period requested as time period during which have been a member of the it is not material to the jurisdictional You were or have been a organization(s). issues raised in the motions to dismiss. member of the organization(s). 17 Identify all charities, This interrogatory is unduly Identify all charities, Without waiving the groups, clubs, or other burdensome, not proportional to the groups, clubs, or other objection and subject to it, organizations which You, needs of jurisdictional discovery, non-profit organizations Mr. Vik will answer for your wife, or children overbroad, vague, and not reasonably which You or your wife himself only. have been involved in or calculated to lead to the discovery of have been involved in or have donated money to in admissible evidence. See Practice have donated money to in the State of Connecticut Book § 13-2. In addition, the the State of Connecticut between January 2000 and i